AUSTRAC Reporting Entity Forum — Bullion Sector
AUSTRAC's recent supervision findings specific to the bullion sector, including findings from the 2024 Compliance Report and key changes for the reforms to Australia's AML/CTF regime.
About this webinar
In May and June 2025, AUSTRAC hosted the Reporting Entity Forum — a series of webinars providing sector-specific feedback and direct interaction with the regulator. AUSTRAC noted that a dedicated bullion supervision team has been newly created specifically to focus on the sector, in response to identifying bullion as a regulatory priority. At the time of this webinar, the team's activities with the bullion sector had only recently commenced.
Why bullion is a regulatory priority
AUSTRAC explained the bullion sector has been prioritised due to rapid growth, concerns about AML/CTF compliance levels, and intelligence-led concerns. The sector is exposed to money laundering and terrorism financing (ML/TF) risk through:
Cash intensity
Many bullion dealers operate cash-intensive business models. Cash transactions are harder to trace.
Store and move funds
Bullion is easy to move domestically and abroad — a stable store of value with less visibility than cash.
Multiple delivery channels
Face-to-face, online, phone sales, and third-party arrangements — each carrying different risk profiles.
AUSTRAC also said: consider how the current instability in global markets could potentially make bullion a more attractive asset class to criminals.
What AUSTRAC found — areas for improvement
ML/TF Risk Assessments
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AUSTRAC is concerned with risk assessments not being tailored to the business, not being underpinned by qualitative and quantitative data, not backed by evidence, and failing to consider known ML/TF typologies. AUSTRAC said: "No two businesses are the same and this also applies to the risks your business faces." You must measure the level of risk for every designated service and rank each as low, medium, or high risk.
AML/CTF Programs
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AUSTRAC observed that some reporting entities do not have an AML/CTF program at all, even though they are required by law to have one. Where programs exist, they are often not tailored to the reporting entity or do not clearly outline the ML/TF systems and controls in place. AUSTRAC said: "There is no one size fits all AML/CTF program."
Customer Risk — Know Your Customer (KYC)
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Only 18% of bullion reporting entities reported having high-risk customers in the 2024 compliance report. AUSTRAC said this indicates deficiencies in some entities' understanding of risk. For high-risk customers, additional KYC steps are required — including asking about source of wealth and taking reasonable measures to verify it.
Suspicious Matter Reporting
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The number of SMRs being reported in the bullion sector is low, and many are of low quality. AUSTRAC said this indicates low understanding of suspicious activity indicators.
Transaction Monitoring Programs (TMPs)
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A Transaction Monitoring Program (TMP) is the system a reporting entity uses to monitor customer transactions for unusual or suspicious activity — for example, structuring (splitting cash to avoid the $10,000 threshold), sudden spikes in activity, or transactions inconsistent with what you know about the customer. It can be manual (staff reviewing transactions) or automated (software that flags alerts). AUSTRAC requires it to be linked to your ML/TF risk assessment. From the 2024 data: only 39% of TMPs in the bullion sector detected suspicious matters in the past year, and 75% of TMPs were manual. AUSTRAC said entities that reviewed their TMP in the past year were more than twice as likely to detect suspicious activity (48% vs 22%). AUSTRAC said: "Your transaction monitoring program is not set-and-forget."
Independent Reviews
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Only 55% of bullion AML/CTF programs have been independently reviewed. AUSTRAC said this means programs are not being tested to ensure their effectiveness. The reviewer must be genuinely independent — not involved in developing the program, assessing ML/TF risk, building controls, or implementing the program.
Suspicious activity indicators for bullion
AUSTRAC listed these examples. No single indicator is conclusive — consider all information and circumstances together.
A customer buys or sells bullion frequently at a loss
Purchases bullion in multiple transactions to avoid the $5,000 customer identification threshold or the $10,000 transaction reporting threshold
Has an account paid into by a third party
Enquires about transaction limits or requests their transaction not be reported
Is uninterested in the details of the purchase — price, transaction fees, delivery costs, or storage fees
2024 Compliance Report data — bullion sector
70%
reviewed or updated ML/TF risk assessment
23%
did so in response to AUSTRAC feedback
18%
reported having high-risk customers
75%
of TMPs were manual
39%
of TMPs detected suspicious activity
55%
had independently reviewed their program
AUSTRAC's enforcement message
"AML/CTF is not a set-and-forget regime. You need to ask: how does ML/TF risk actually play out in your business and where are the real vulnerabilities? And how are you monitoring whether your controls are working and what happens if they're not?"
— AUSTRAC Bullion Sector Forum, July 2025
Cooperation matters
AUSTRAC said open, proactive communication with AUSTRAC — particularly where significant compliance concerns arise — is the most effective way to mitigate broader consequences. A culture that encourages avoidance or compliance window dressing will be a focus of AUSTRAC's enforcement work.
Disclaimer: Published by GetPost Labs Pty Ltd for educational purposes only. Not legal, financial, or compliance advice. Summary of publicly available AUSTRAC content — original: AUSTRAC Reporting Entity Forum — Bullion Sector, 17 July 2025. Refer to austrac.gov.au. Errors: sumit@getpostlabs.io